Towards implementing European
Public
Sector Accounting Standards
(EPSAS) for EU Member States Public consultation on future EPSAS
governance principles and structures
Identification of the respondent:
Name

Martin Dees and Patrick Schuerman
Profession (if applicable)
Name of Institution/Organisation (if you reply on behalf of one)

Ministry of Finance, the Netherlands
Transparency Register ID (if applicable)

Address

P.O. Box 20201, 2500 EE The Hague
Email
m.dees©minfin.n1; p.e.m.w.schuerman@minfin.n1

Country

The Netherlands
Type of respondent

Public Authority national level

Questionnaire
1. Please state the main motivation of your interest in this public consultation.*

The Ministry of Finance of the Netherlands is a key player regarding public accounting
standards in the Netherlands. The Ministry has co-responsibility for preparation of and
sound EU decision making on EPSAS-plans, and a key responsibility for implementation
of potential EPSAS in The Netherlands.
Key governance principles
2. Do you consider that the sets of principles described for the EPSAS
governance structure and process as well as for the EPSAS standards are
relevant?

In principle yes (see also answer to question 11)

3. Please provide any comments or proposals on the principles.
See answer to question 11

Governance oversight
4. Following the normal institutional organisation within the EU, the EPSAS
governance would be subject to oversight by the Commission itself, and by the
Council, the European Parliament and the European Court of Auditors. Do you
consider that any further oversight function should be established?
Yes, the Economic and Financial Committee should be included as an additional oversight
function. The European Court of Auditors has an independent audit function rather than
an oversight function. It should be emphasized that the European Council and the
European Parliament should be the bodies with responsibility in the EU for the
development, including changes in, and introduction of EPSAS standards (for the total as
for the individual EPSAS). Subsidiarity should play an important role in designing the
institutional organization.
4a. Do you consider that the oversight role of the EPSAS Governance Advisory
Board as outlined in the consultation paper would be appropriate for EPSAS?*
No, the role of the EPSAS Governance Advisory board should be primarily interpreted as
an advisory role rather than an oversight role. Therefore, we don't agree that a task
like providing annual reports on the implementation of key principles should be part of
their role.
5. Please provide any comments or proposals on the oversight.
-

Stakeholder involvement
6. Taking into account that stakeholders' views could be collected by open
consultations during the standard setting process, do you consider that an
organised, formal representation of EPSAS stakeholders should be established?
Yes, of course
6a. Do you consider that the role of the EPSAS Technical Advisory Group as
outlined in the consultation paper would be appropriate for EPSAS?*
Yes
7. Please provide any comments or proposals on stakeholder involvement.

8. If you think that both the EPSAS Governance Advisory Board and the EPSAS
Technical Advisory Group would be appropriate for EPSAS, could their role and
tasks be fulfilled by a single advisory group?
No, see answer to 8a.
8a. Please provide any comments or proposals on a single advisory group.

Governance on the one hand and technical aspects on the other are fundamentally
different subjects — the former being process-oriented and the Jatter content-oriented.
Correspondingly, the required competences for advising on these matters differ
considerably.

interpretation of the standards
9. Do you consider that an interpretation function should be foreseen for
EPSAS?
Yes, but not in the first stage of EPSAS. In the first stage of EPSAS, the individual EPSAS
should give the guidance needed / be clear enough for the users.

9a. Do you consider that this interpretation function should be kept separate
from the standard setting function?
No, as both functions are from a conceptual point of view inseparable.Furthermore, the
interpretation function should be closely connected to the standard setting function
because the standard setters know best which accounting practice they intend to
promote with the standard..

10. Please provide any comments or proposals on the interpretation?
As regards the interpretation of the EPSAS it is important that the member states play a
key role justified by the European character of EPSAS.

11. Do you have any additional comments concerning the proposed EPSAS
governance structure?
The governance structure should be explicitly based on and justified by a clear and
focused demarcation of the objectives and scope of the EPSAS. In our opinion, for
reasons of subsidiarity, national competences and proportionality between cost and
benefits (as emphasized in the Ecofin conclusion of 15 November 2013), the objective of
EPSAS should be restricted to the specific purpose of ensuring the production of reliable,
comparable and timely fiscal data at the macro-level. Therefore, the project should be
limited to the necessary improvements of the micro-accounting systems - in order to
ensure comparable and coherent upstream accruals data (i.e. the primary accounting
data for government entities)
leaving the national financial reporting systems and the
budgeting systems to the domein of the member states. The governance structure should
be brought in line with this confined purpose. In line with the subject of article 3 of
Directive 2011/85/EU, a future `EPSAS' should rather be an accounting procedure (i.e.,
a standard on when and how to record which transactions and other relevant information
in which way) than a financial reporting guideline, keeping deviations from ESA 2010
concepts as iimited as possible. This would create cost-effective conditions for the future
perspective - described in the EPSAS-report of May 2013 - of deriving the debt and
deficit data directly from the micro accounting systems as much as possible.Since the
national statistical offices are probably the main users of the financial micro-information
provided by government entities, their interests should be substantially reflected in the
composition and working procedures of the various EPSAS-boards and groups.
Furthermore, regarding the development of (the individual) EPSAS it is important to
start with the development of individual epsas which are most relevant for the
government. Not the other way round: simply translating existing individuel IPSAS in
individual EPSAS. For example the for typical government activities such as taxes, social
contributions and social protection as guidance is needed most.
As regards the governance of the EPSAS it is necessary that all the member states are
represented in the foreseen boards given the importance of accounting systems for
national governments.

Last, but not least, it should be mentioned that EPSAS should become available in all
languages of the member states.
12. Here you can upload any files that you consider important to share with us
in the context of this
public consultation.
No files